A&G Newsletter – Q1 2026

I. CBAM: authorisation

As of 1 January 2026, CBAM has entered its definitive regime. Importers of CBAM goods (or their indirect customs representatives) should apply for authorised CBAM declarant status, and customs systems are validating authorisations before release for free circulation. CBAM certificates will be sold from 1 February 2027 (for 2026 imports), according to Commission guidance.

Why it matters: CBAM has moved from reporting-only to a live border and compliance workflow. Companies should secure authorisation, align customs processes, and start budget planning for the certificate phase.

II. DAC8: crypto reporting

DAC8 rules entered into force on 1 January 2026, expanding EU tax transparency to crypto-asset transactions. Reporting Crypto-Asset Service Providers should start collecting reportable data from 2026, with reporting due within 9 months after the end of the first fiscal year covered (i.e., by 30 September 2027 for the first cycle).

Why it matters: Providers – especially those operating cross-border – should confirm registration approach, due diligence, data capture and reporting readiness well ahead of the first reporting deadline.

III. EuroHPC: AI gigafactories

On 16 January 2026, the Council adopted an amendment to the EuroHPC framework to facilitate the creation of AI gigafactories and introduce a dedicated quantum technologies pillar.

Why it matters: Access rules, PPP structures, and funding/procurement design will shape who benefits from Europe’s next generation compute infrastructure – particularly for AI-intensive sectors and scale-ups.

IV. Horizon: AI calls

The Commission has launched calls allocating over EUR 307 million for AI and related technologies, with the application window open until 15 April 2026.

Why it matters: Early coalition-building and policy alignment can be decisive in competitive calls – particularly for consortia combining industry, research, and public stakeholders.

V. Customs: e-commerce checks

A large-scale EU customs control action found that many third-country e-commerce goods shipped directly to consumers fail to meet EU rules or pose serious risks, underlining the capacity gap created by rapidly growing parcel volumes.

Why it matters: Expect tighter scrutiny at the border, stronger coordination with market surveillance authorities, and increased compliance expectations for platforms, importers-of-record, and supply chains serving the EU consumer market.

VI. Auto: package

The Commission presented its automotive package and signalled measures and policy direction to support a clean and competitive automotive sector, including ongoing debate about flexibility and technological neutrality in the CO2 standards pathway, including references to e-fuels and biofuels in the post-2035 context.

Why it matters: The package opens a new political cycle for automotive regulation (standards, incentives, industrial tools). Companies should position early on implementing measures and any legislative follow-ups that affect product strategy and investment planning.

VII. EUDR: delay

The Parliament and Council adopted changes postponing application of the EU deforestation rules to 30 December 2026 for operators, with a further extension for micro and small operators to 30 June 2027, alongside targeted simplifications.

Why it matters: Companies should use the additional time to stabilise traceability, geolocation, supplier onboarding and due diligence workflows – while monitoring guidance and any new reporting/IT-system requirements.

VIII. Council: Cyprus

Cyprus holds the Presidency of the Council of the EU from 1 January to 30 June 2026, setting early-2026 Council rhythm and shaping how quickly priority files move through working parties and COREPER.

Why it matters: For fast-moving files, aligning outreach with the presidency’s calendar can materially improve timing, coalition-building and message traction.

Also on the regulatory radar this quarter

Trade defence and foreign subsidies enforcement continues to intensify, and deal planning should factor investigation and review timelines. Digital and AI implementation shifts from legislation to standards, guidance, and enforcement sequencing across sectors. Single Market enforcement remains focused on e-commerce, product compliance, and customs capacity constraints.

Key dates & actions

CBAM: ensure authorised declarant status is in place for 2026 imports and prepare for certificates sold from 1 February 2027. DAC8: start collecting reportable transaction data from 1 January 2026; first-cycle deadline 30 September 2027. Horizon Europe AI calls: deadline 15 April 2026. EUDR: postponed application 30 December 2026 (and 30 June 2027 for micro/small).

If any of these files affect your operations, supply chains, workforce, or transactions, A&G can design tailored engagement strategies with the Commission, Parliament, Council, and national authorities – leveraging structured advocacy, coalition-building, and technical input to shape outcomes.